Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Deemed dividend addition u/s 2(22)(e) - Inter-Corporate Deposit (ICD) - Deposit agreement or any other bilateral agreement, which would bring out the terms and conditions and the features of the transaction as understood by the parties, it would not be appropriate to say that it is in the nature of an ICD and not a loan. - Liable to tax as deemed dividend.
Deemed dividend addition u/s 2(22)(e) - Inter-Corporate Deposit (ICD) - Deposit agreement or any other bilateral agreement, which would bring out the terms and conditions and the features of the transaction as understood by the parties, it would not be appropriate to say that it is in the nature of an ICD and not a loan. - Liable to tax as deemed dividend.
Note: It is a system-generated summary and is for quick reference only.